A Letter to COSEPUP
Members of the Committee,
I am Dr. Norman Anderson, CEO of the American Psychological Association representing 155,000 members and affiliates. Thank you for inviting my colleague, Dr. Mumford and me to participate in this important discussion. We've been asked to briefly respond to 4 questions:
1. What are your general thoughts regarding the issue of science, engineering, and health professional appointments to federal advisory committees?
In general the overall appointment process appears to function reasonably well. However, irregularities in the system may contribute to the erosion of trust by appointees, government agencies and the public. Because of the range of agencies they serve, different advisory bodies are comprised of different types of scientific, technical and professional expertise. But it should be clear what type of expertise any individual brings to the table and the process of vetting appointees should be made as transparent as possible. For scientist nominees such vetting should be based soley on their scientific credentials.
2. Do you believe that COSEPUP should undertake a study to identify the principles that should guide such appointments?
Absolutely. I'm aware that such studies have been conducted by the IOM, such as the Committee to Study the Use of Advisory Committees by the Food and Drug Administration. But because of the breadth of COSEPUP's charter, it is uniquely situated to examine the appointment process across the full range of government agencies serving our science and technology enterprise.
3. What are your thoughts on the proposed statement of task?
The statement of task is comprehensive and appears to fit well within the scope of COSEPUP's charter and expertise. It is particularly timely given the questions circulating within the scientific community on this general issue. We believe that the scientific community and the public at large need reassurance that federal advisory committee nominees are being evaluated systematically, based on their scientific and professional credentials. While it is the prerogative of each administration to decide what to do with the science advice it receives, each administration should commit to engage the best scientists in developing that advice. The General Services Administration's guidance on the implementation of the Federal Advisory Committee Act indicates that agencies are expected to assure that major---and sometimes strongly opposing---viewpoints are represented to provide a foundation for developing advice and recommendations that are fair and comprehensive. The questions COSEPUP is proposing to address would provide some much needed clarification of the appointment process.
4. If a study is undertaken, what type of individuals should be on the committee? Who should chair it? What should be the timeframe?
It will be challenging to assemble a manageable sized group with the necessary range of expertise. It would seem that members of the Federal Science Advisory Committee Guidance Group which includes the White House Science Advisors for several previous administrations could be especially helpful. Given the similarity in mandates, the committee would benefit from input provided by the members of the IOM committee that examined appointments at the FDA. Members of the IOM group could provide valuable insights that could help expedite the work of the new committee. Given the level of concern expressed within the scientific community surrounding the vetting of prospective committee members, I would hope the work of the committee could be completed as expeditiously as possible. Thank you.